This is a response to Dave Schwab’s article, “Experts at odds on how to stave off Sunset Cliffs erosion,” in the July 25 Beacon.

The article touches on water quality and stormwater management issues at the Sunset Cliffs Natural Park’s park that we and others discussed at the

July 18 Peninsula Community Planning Board (PCPB) meeting relative to a California Coastal Conservancy grant to the city for hillside park improvements.

Having been involved for over 20 years to enhance and bring back the precious resource that is Sunset Cliffs Natural Park, including leading the successful effort to obtain the park master plan in 2005, we want to be clear that we support the proposed significant re-vegetation efforts and improving trails within the park.

What we would like to clarify is why we are opposed to the use of a traditional storm drain with ocean disposal in the park. Installation of these large pipes at the base of slopes will not control erosion upslope, thereby will allow sediments and other pollutants (hydrocarbons, fertilizers, pesticides, animal waste) to enter the drainage system and be discharged through a dilapidated concrete swale to the center of Garbage Beach, causing marine pollution and increasing public health risks for eye, ear, skin and gastric infections.

Low-impact development/best management projects (LID/BMPs) are what are called for by state Water Quality Control Board regulations (MS4) to protect people and the marine habitat from pollution. Basically, the MS4 regulations call for measures to be implemented at the source of the runoff to prevent erosion through infiltration or use, treat pollutants and thus avoid the costly, highly disruptive and ineffective installation of over 2,500 linear feet of 12” and 18” pipes, as is proposed.

The city is a co-permittee to these regulations (2007 and May 8, 2013), so it is perplexing why the plans for the hillside improvement project are not trying to control runoff and pollutants generated on park property at the source.

At the PCPB meeting, city engineer Ali Darvishi stated that the city is exempt from following MS4 stormwater regulations that have been in place since 2007. We have not been able to find this exemption and people knowledgeable about regulatory matters state on the contrary that all projects are required by MS4 regulations, starting with planning, to implement minimum post-construction LID/BMPs.

LID/BMPs used at the source, before storm water is contaminated with erosion sediment and other pollutants, provide:

(1) Control and treatment of upslope stormwater running off impervious surfaces.

(2) Treat stormwater using bio-swales and other BMPs to remove pollutants that now contaminate the park, surfing locations and other beneficial-use areas of Garbage Beach, thus reducing infections contracted by people using these ocean waters.

(3) Reduce degradation of intertidal habitats and harm to marine plants and animals that now occurs.

(4) Use captured stormwater to promote the growth of native plants such as Torrey pines and oak trees that native Americans living on Point Loma farmed for their acorns.

We are proposing an adjunct study (total cost about $35,000) be added to the improvements project that would consider where it would be appropriate to use BMPs for runoff control. This adjunct study would allow the Point Loma community to evaluate varying methods for controlling storm water in the park.

The California Coastal Conservancy has told us it wants the hillside improvements done right, and are willing to extend the grant period to ensure the project conforms to the MS4 regulations. We have been attempting to get the city to incorporate LID/BMP measures in the hillside improvements project for two years. Why is the city resisting complying with these regulations and protecting people who use this popular body contact area?